Ethics Code

The Capital Times Code of Ethics are fundamental to the values of the company and essential to achieving its mission to lead the investment profession by promoting the highest standards of ethics, education, and professional excellence for the ultimate benefit of society

Capital Times employees must:

Act with integrity, competence, diligence, respect and in an ethical manner with the public, clients and colleagues in the investment profession, and other participants of capital markets

Place the interests of clients above their own personal interests.

Use reasonable care and exercise independent professional judgment when conducting investment analysis or recommendations

Maintain and improve their own professional competence and strive to maintain and improve the competence of other investment professionals

Knowledge of the Law. Capital Times employees must understand and comply with all applicable laws, rules, and regulations of any government, regulatory organization or licensing agency.

Independence and Objectivity. Capital Times employees must use reasonable care and judgment to achieve and maintain independence and objectivity in their professional activities.

Misrepresentation. Capital Times employees must not knowingly make any misrepresentations relating to investment analysis, recommendations, actions, or other professional activities.

Misconduct. Capital Times employees must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence.

INTEGRITY OF CAPITAL MARKETS

Material Nonpublic Information. Capital Times employees who possess material nonpublic information that could affect the value of an investment must not act or cause others to act on the information.

Market Manipulation. Capital Times employees must not engage in practices that distort prices or artificially inflate trading volume with the intent to mislead market participants.

DUTIES TO CLIENTS

Loyalty, Prudence, and Care. Capital Times employees have a duty of loyalty to our clients and must act with reasonable care and exercise prudent judgment.

Fair Dealing. Capital Times employees must deal fairly and objectively with all clients when providing investment analysis, making investment recommendations, taking investment action, or engaging in other professional activities.

Suitability.

Prior to making any investment recommendation or taking investment action Capital Times employees must:

Make a reasonable inquiry into a client’s investment experience, risk and return objectives, and financial constraints

Determine that an investment is suitable to the client’s financial situation and consistent with the client’s objectives, mandates, and constraints

Judge the suitability of investments in the context of the client’s total portfolio

When Capital Times employees are responsible for managing a portfolio, they must make only investment recommendations or take only investment actions that are consistent with the stated objectives and constraints of the portfolio.

Performance Presentation. When communicating investment performance information, Capital Times employees must make reasonable efforts to ensure that it is fair, accurate, and complete.

Preservation of Confidentiality. Capital Times employees must keep information about current, former, and prospective clients confidential

DUTIES TO THE COMPANY

Loyalty. In matters related to the company, Capital Times employees must act for the benefit of the company and not deprive the company of the advantage of their skills and abilities, divulge confidential information, or otherwise cause harm to the company.

Additional Compensation Arrangements. Capital Times employees must not accept gifts, benefits, compensation, or consideration that competes with or might reasonably be expected to create a conflict of interest with the company’s interest.

Responsibilities of Supervisors. Capital Times employees must make reasonable efforts to ensure that anyone subject to their supervision or authority complies with applicable laws, rules, regulations, and the Code.

Disclose to clients the basic format and general principles of the investment processes they use to analyze investments, select securities, and construct portfolios and must promptly disclose any changes that might materially affect those processes.

Use reasonable judgment in identifying which factors are important to their investment analyses, recommendations, or actions and include those factors in communications with clients and prospective clients.

Distinguish between fact and opinion in the presentation of investment analysis and recommendations.

Record Retention. Capital Times employees must develop and maintain appropriate records to support their investment analyses, recommendations, actions, and other investment-related communications with clients.

CONFLICTS OF INTEREST

Disclosure of Conflicts. Capital Times employees must make full and fair disclosure of all matters that could reasonably be expected to impair their independence and objectivity or interfere with respective duties to their clients and company.

Priority of Transactions. Investment transactions for clients and the company must have priority over investment transactions in which a Capital Times adviser is the beneficial owner.

Referral Fees. Capital Times employees must disclose to the company and clients, as appropriate, any compensation, consideration, or benefit received from or paid to others for the recommendation of products or services.

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